H.R. 5346

119th CONGRESS 1st Session

To amend the Internal Revenue Code of 1986 to reform certain penalty and interest provisions.

IN THE HOUSE OF REPRESENTATIVES · September 15, 2025 · Sponsor: Mr. Grothman · Committee: Committee on Ways and Means

Table of contents

• H.R. 5346
  • SEC. 1. Short title
  • SEC. 2. Procedural requirements for assessment of penalties

SEC. 1. Short title

• This Act may be cited as the Fair and Accountable IRS Reviews Act.

SEC. 2. Procedural requirements for assessment of penalties

• (a) Approval of assessment
  • of the Internal Revenue Code of 1986 is amended to read as follows: Section 6751(b)(1)
    • (1) In general
      • No penalty under this title shall be assessed or entered unless, before any written communication with respect to such penalty (including proposal of a penalty as an adjustment) is sent to the taxpayer, the initial determination of such assessment is personally approved (in writing) by the immediate supervisor of the individual making such determination or such higher level official as the Secretary may designate.
• (b) Immediate supervisor defined
  • (3) Immediate supervisor
    • For purposes of this subsection, the term means, with respect to an individual making a determination under paragraph (1), the person to whom such individual reports. immediate supervisor
  • Section 6751(b) of such Code is amended by adding at the end the following new paragraph:
• (c) Effective date
  • The amendments made by this subsection shall apply to notices issued, and penalties assessed, after December 31, 2025.